# T E C H N I C A L 

# S U P P O R T 

# D O C U M E N T

Department of the Environment 

## Amendment to — COMAR 26 .11.19.10 Flexographic and Rotogravure Printing and Adoption of New Regulations COMAR 26.11.19.10-1 Flexible Packaging Printing

Purpose of Action

The purpose of this action is to adopt the requirements of the Environmental Protection Agency (EPA) Control Techniques Guidelines (CTG) fo r flexible packaging printing. EPA develops CTGs as guidance on control requirements for sour ce categories. States can follow the CTGs or adopt more restrictive standards. MDE proposes to adopt the CTG standards for flexible packaging printing and work practices.

Background

EPA developed the CTG after conducting a review of currently existing state and local VOC emission reduction approaches for flexible package printing, review ing the 1978 CTG and the 1996 NESHAP for the printing and publishing indus try (40 CFR Part 60, Subpart KK), which is applicable to flexible package printing and taking into account the information that has become

available since then.

Flexible packaging refers to any package or part of a package the shape of which can be readily changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or any combination of these materials. Flexible packaging materials start out as rolls of paper or foil, or beads of plastic resin, and are converted into a package or roll of packaging material.

Any printing of shrink-wrap labels or wrappers conducted on or in -line with a fl exible package printing press is also considered to be include d under the flexible packaging source category. Printing of self-adhesive labels is not included in flexible packaging.

Rigid packaging printing operations are often times co-located with flexible package printing operations. Folding cartons, some labels and wrappers, gift wraps, wall coverings, vinyl products, decorative laminates, floor coverings, tissue products , and miscellaneous specialty products are not considered flexible packaging.

Flexographic and rotogravure presse s are used in flexible packag ing. There are two main sources of VOC emissions from flexible package prin ting for both flexographic and rotogravure: (1) evaporation of VOC from inks, coatings, and adhesives, and (2) evaporation of VOC from cleaning materials.

1Sources Affected

This action will affect sources that use flexograp hic and rotogravure presses to print flexible packaging materials.

Requirements

COMAR 26.11.19.10 is amended to state that the re quirements for flexible packaging printing

are in COMAR 26.11.19.10-1 Flexib le Packaging Printing. Standards for flexible packaging printing lines are:

1. 0.8 lb VOC/lb or kg VOC/kg solids applied; or 2. 0.16 lb VOC/lb or kg VOC/kg materials applied; or

If a control device is used: The dryer exhaust is required to be ducted to a control device that is constructed, operated, and

maintained to achieve various overall control effi ciencies based on the installation date of the Flexible Packaging line and air pollution control device.

The work practice standards apply to the usage of all VOC containing materials.

Basis for Emission Standards

The CTG standards are:



### • 65 percent overall control for a press that was first installed prior to March 14, 1995 and that is controlled by an add-on air pollution control device (APCD) whose first installation date was prior to the effective date.



### • 70 percent overall control for a press that was first installed prior to March 14, 1995 and that is controlled by an add-on APCD whose first installation date was on or after the effective date

of the rule.



### • 75 percent overall control for a press that was first installed on or after March 14, 1995 and that is controlled by an add-on APCD whose first installation date was prior to the effective date of

the rule.



### • 80 percent overall control for a press that was first installed on or after March 14, 1995 and that is controlled by an add-on APCD whose first installation date was on or after the effective date

of the rule.

Equivalent Standards

The CTG provides two optional standards that ca n be met with the use of low VOC content

materials or combinations of materials and cont rols as follows: (1) 0.8 kg VOC/kg solids applied, or (2) 0.16 kg VOC/kg materials applied.

DRAFT 12/15/2009 1:10 PM 2DRAFT 12/15/2009 1:10 PM 3 Expected Emissions Reductions

This proposed action sets standards for flexible packaging printing. VOC emissions reductions in Maryland would be approximately 0.08 tons/day.

Health Effects and Ground-Level Ozone

The maximum benefit from these amendments will be provided during the ozone season when VOCs readily combine with NOx to form the pollutant ground level ozone.

Economic Impact

The economic impact of implementing CTG requirements has been estimated by EPA on a national level. Cost effectiveness is appr oximately $1,400-2,400/ton of VOC controlled. The impact on the Department is going to be minima l as affected sources are already regulated. The Department will need to review additional r ecords and ensure new standards are being met.

Revision to Maryland's SIP

This action will be submitted to the U.S. EPA fo r approval as a revision to Maryland's State Implementation Plan.

Other State or Federal Requirements

There are no other state or fede ral reasonably available control technology standards for this category. Multiple facilities are covered under this CTG and each may be subject to additional federal requirements.

Comparison to Federal Standards

There is a corresponding federal standard to this proposed acti on, but the proposed action is not more restrictive or stringent.

References

Control Techniques Guidelines for Flexible Package Printing (EPA 453/R-06-003 September 2006)